Privacy Policy

1. INTRODUCTION

    1. This Privacy Policy is provided by Stylefrog Creative Ltd. (trading as Stylefrog Creative), a company registered in England and Wales under company number: 08216427 with registered office at 3, Paradise Ave, Kettering NN15 6LU, United Kingdom (‘we’, ‘our’ or ‘us’) for use of our website, being www.stylefrogcreative.com (Website).
      We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).
      It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
      We are the controller of personal data obtained via the Website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

2. WHAT THIS POLICY APPLIES TO

    1. This privacy policy relates to your use of the Website and accessing the services provided through the Website.
      The Website may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with the services through the Website. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

3. PERSONAL DATA WE COLLECT ABOUT YOU

    1. The personal data we collect about you depends on the particular activities carried out through the Website. We will collect and use the following personal data about you:

      Category of data

      In more detail

      Data collected when you use specific functions in the Website

      Data you store online with us using the Website including your usage history or preferences (while such data may not always be personal data as defined at law in all cases, we will assume it is and treat it in accordance with this policy as if it were)

      Other data the Website collects automatically when you use it

      Your activities on, and use of, the Website which reveal your preferences, interests or manner of use of the Website and the times of use. Other analytical information such as, device type, IMEA numbers, MAC address of networks, other unique device identification, device operating system, mobile network information, app version number, storage usage, data usage, time zone settings, geographical location etc. is also likely to be collected in the course of your use of the Website.

      Data collected when you make an enquiry with us

      Your name and email address

     

    If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services to you through the Website.
    We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ usage data (including information about how users interact with and use the Website and products and services offered through the Website) to calculate the percentage of users accessing a specific feature of the Website in order to analyse general trends in how users are interacting with the Website to help improve the Website and our offerings.
    We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

4. SENSITIVE DATA

    1. Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
      Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.
      If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Website (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.

5. HOW YOUR PERSONAL DATA IS COLLECTED

    1. We collect personal data from you directly when you submit the enquiry form through the Website, contact us directly or reach out to us via social media, or indirectly, such as your activity while using the Website.
      At this point in time, we do not collect any personal information about you using cookies or similar technologies. In the event that this were to change and if we were to decide to collect personal data about you using cookies, you would be notified of this change by means of in-app notification, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant cookies policy.

6. HOW AND WHY WE USE YOUR PERSONAL DATA

    1. Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
      • where you have given consent
      • to comply with our legal and regulatory obligations
      • for the performance of a contract with you or to take steps at your request before entering into a contract, or
      • for our legitimate interests or those of a third party
      A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

      The table below explains what we use your personal data for and why.

      What we use your personal data for

      Our reasons 

      Create and manage your account with us

      To perform our contract with you or to take steps at your request before entering into a contract

      To verify your identity

      This may be against public databases via our Identification Verification partners.

      Providing services and/or the functionalities of the Website to you

      Depending on the circumstances to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website).

      To enforce legal rights or defend or undertake legal proceedings 

      Depending on the circumstances:

      • to comply with our legal and regulatory obligations
      • in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others

      Sending relevant marketing communications and for making personalised suggestions and recommendations to you about the products that may be of interest to you based on your profile data

      For our legitimate interests, to carry out direct marketing, develop our products and grow our business and having obtained your consent to receive direct marketing communications.

      Carry out market research through your voluntary participation in surveys

      Necessary for our legitimate interests to study how customers use the products, use our Website and to help us improve and develop our Website and products and services offered through the Website.

      Communications with you not related to marketing, including about changes to our terms or policies or updates concerning the order placed by you through the Website or changes to the Website or service or other important notices

      Depending on the circumstances:

      • to comply with our legal and regulatory obligations
      • to keep you updated on the orders placed by you
      • in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you

      Protect the security of systems and data 

      To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

      Operational reasons, such as improving efficiency, training, and quality control or to provide support to you

      For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you

      Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures

      For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app

      Updating and enhancing user records

       

      Depending on the circumstances:

      • to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website)
      • to comply with our legal and regulatory obligations
      • where neither of the above apply, for our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Website and the products and services offered through the Website

      To comply with our legal and regulatory obligations

      Depending on the circumstances:

      • to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website)
      • to comply with our legal and regulatory obligations

      where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Website

      To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.
      In such cases information will be anonymised where possible and only shared where necessary

      Depending on the circumstances:

      • to comply with our legal and regulatory obligations
      • in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

     

    See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

7. MARKETING

    1. We intend to send you email marketing to inform you of the products such as promotions, any new products etc.
      We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.
      You will have the right to opt out of receiving marketing communications at any time by:
      • contacting us at [hello@stylefrogcreative.com]
      • using the ‘unsubscribe’ link included in all marketing emails you may received from us
      We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
      For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

8. WHO WE SHARE YOUR PERSONAL DATA WITH

    1. We routinely share personal data with service providers we use to help us run our business, help us with fulfilment of the orders placed through the Website such as payment aggregators, logistics provider, or provide the services or functionalities in the Website, including developers, cloud storage providers etc.
      We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
      We or the third parties mentioned above may occasionally also need to share your personal data with:
      • external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
      • professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
      • law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
      • other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
      If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
      We will not share your personal data with any other third party.

9. HOW LONG YOUR PERSONAL DATA WILL BE KEPT

    1. We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.
      Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.

10. TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA

    1. Your personal data is currently primarily stored and processed within the European Union (“EU”) and the United Kingdom (“UK”). We do not currently intend to transfer your personal data outside of the UK or the European Economic Area (“EEA”). If this changes, we will comply with applicable data protection laws designed to ensure the continued protection and privacy of your personal data.

      Any material changes to the international transfers described in this section will be reflected in updates to this Privacy Policy in accordance with the section on “Changes to this Privacy Policy” below.

      Under applicable UK and EU data protection laws, we may only transfer your personal data to a country outside the UK or EEA where:
      • the relevant authority has determined that the country ensures an adequate level of protection for personal data (for example, pursuant to an adequacy regulation or adequacy decision under Article 45 of the UK GDPR or EU GDPR);
      • appropriate safeguards are in place and enforceable rights and effective legal remedies are available to you; or
      • specific exception applies under relevant data protection law.

      Accordingly, if we transfer your personal data outside the UK or EEA in the future:
      • transfers from the UK to the EEA would rely on the adequacy arrangements recognised under UK data protection law;
      • transfers from the EEA to the UK would rely on the European Commission’s adequacy decision for the UK; and
      • transfers to countries outside the UK and EEA would rely on appropriate safeguards under applicable data protection laws, such as the incorporation of the European Commission’s approved Standard Contractual Clauses, together with the UK International Data Transfer Addendum or other approved transfer mechanisms where required, into our data processing agreements.


    Where we cannot rely on an adequacy decision or appropriate safeguards, we would only transfer your personal data where another lawful transfer mechanism or exception applies under applicable data protection law.

11. YOUR RIGHTS

    1. You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

      Access to a copy of your personal data

      The right to be provided with a copy of your personal data.

      Correction (also known as rectification)

      The right to require us to correct any mistakes in your personal data.

      Erasure (also known as the right to be forgotten)

      The right to require us to delete your personal data—in certain situations.

      Restriction of use

      The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.

      Data portability  

      The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

      To object to use

      The right to object:

      • at any time to your personal data being used for direct marketing (including profiling)
      • in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.

      Not to be subject to decisions without human involvement

      The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

      For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
      If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’.

      When contacting us please:
      • provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
      • let us know which right(s) you want to exercise and the information to which your request relates

12. KEEPING YOUR PERSONAL DATA SECURE

    1. We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
      We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
      If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

13. HOW TO COMPLAIN

    1. Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
      You also have the right to lodge a complaint with the Information Commissioner.
      The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

14. CHANGES TO THIS PRIVACY POLICY

    1. We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Website or by other means, such as email.

15. HOW TO CONTACT US

    1. You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

      Our contact details are shown below:
      • Stylefrog Creative Ltd. 3 Paradise Avenue, Kettering, Northants NN15 6LU
      • hello@stylefrogcreative.com
      • +44(0)1536 516636